Deduction under Section 80GGC disallowed as political donation was bogus and returned in cash. Issue Whether an assessee is entitled to claim a deduction under Section 80GGC for a donation made to a political party when investigative findings establish that the donation was bogus and the funds were routed back to the assessee in cash.… Read More »
TDS Credit Omitted in Original Return Must Be Granted on Rectification if Reflected in Form 26AS Issue Whether an assessee who omitted to claim credit for tax deducted at source (TDS) in the original return filed under Section 139(1) can claim the TDS credit via a rectification application under Section 154, when the TDS is… Read More »
Delay of 22 Days in Filing Form 10B Does Not Bar Section 11 Exemption if Report is Available Before Processing Issue Whether an assessee registered as a charitable trust/section 8 company can be denied exemption under Section 11 of the Income-tax Act, 1961 due to a 22-day delay in submitting Form 10B prior to the… Read More »
Minor Nine-Day Delay in Filing Form 10-IE Due to Portal Glitches Cannot Deny Section 115BAC Benefit Minor Nine-Day Delay in Filing Form 10-IE Due to Portal Glitches Cannot Deny Section 115BAC Benefit Issue Whether a technical and minor delay of nine days in filing Form No. 10-IE due to e-filing portal glitches can justify the… Read More »
Reassessment Notice Issued Beyond Three Years Under Section 148 Without Section 151(ii) Approval Lacks Valid Jurisdiction Reassessment Notice Issued Beyond Three Years Under Section 148 Without Section 151(ii) Approval Lacks Valid Jurisdiction Issue Whether a consequential reassessment notice issued under Section 148 after the expiry of three years from the end of the relevant assessment… Read More »
Reassessment Proceedings Conducted by NFAC Prior to Statutory Notification Date of 29.03.2022 Are Void Ab Initio Reassessment Proceedings Conducted by NFAC Prior to Statutory Notification Date of 29.03.2022 Are Void Ab Initio Issue Whether faceless reassessment proceedings assumed and completed by the National Faceless Assessment Centre (NFAC) prior to the notification of the ‘e-Assessment of… Read More »
Reassessment Proceedings Conducted by NFAC Prior to Notification Date of 29.03.2022 Are Void Ab Initio Reassessment Proceedings Conducted by NFAC Prior to Notification Date of 29.03.2022 Are Void Ab Initio Issue Whether faceless reassessment proceedings assumed and completed by the National Faceless Assessment Centre (NFAC) prior to the notification of the ‘e-Assessment of Income Escaping… Read More »
Reopening under Section 148 is invalid if based on incorrect facts and non-existent transaction figures Reopening under Section 148 is invalid if based on incorrect facts and non-existent transaction figures Issue Whether an assessment reopening under Section 148 of the Income-tax Act, 1961 (Section 280 / Section 102 of the Income-tax Act, 2025) is legally… Read More »
Concluded APA Implementation Upheld for Transfer Pricing and Disallowances Deleted Following Past Judicial Precedents Issue Whether transfer pricing adjustments under Chapter X (AMP expenses, royalty, HQ expenses, service warranty) must be recomputed in terms of a concluded Advance Pricing Agreement (APA) under Section 92CC covering the relevant assessment and rollback years. Whether disallowances of expatriate… Read More »
Unexplained Cash Deposits Cannot Claim Section 10(26) Exemption and Are Taxable Under Section 69A Issue Whether cash deposited in bank accounts by a Scheduled Tribe individual can be treated as exempt income under Section 10(26) when the assessee fails to establish a valid and verifiable source for such cash deposits. Facts Assessee Status: The assessee… Read More »